oil and gas floodplain regulation amy brandley, cfm floodplain administrator, canadian county, ok
TRANSCRIPT
Oil and GasFloodplain Regulation
Amy Brandley, CFM
Floodplain Administrator, Canadian County, OK
Canadian County, Oklahoma
900 square miles
Fastest growing county in OK
Canadian County, Oklahoma:
Third in the nation in the number of Federally Declared Disasters over the last decade.
-USA Today, Feb 11, 2008
Tornadoes
Wildfires
Ice Storms
Floods
Giant Fish
Oklahoma Flood Facts
• Of the 58 Major Disaster Declarations in Oklahoma since 1955, 40 have involved flooding. (FEMA)
• Oklahoma is consistently recognized by FEMA and others as having the best floodplain management program in Region VI and one of the top programs in the country.
OK is one of the top producers of oil and gas in the nation
But…
• Many Oklahoma communities are not following floodplain regulations for oil and gas development in their floodplains.
• O/G is heavily regulated by the Oklahoma Corporation Commission, but they don’t require any floodplain management practices.
Where We Have Been
• We have worked with the Oklahoma Water Resources Board, the Oklahoma Corporation Commission, the Oklahoma Independent Petroleum Association, local regulatory permitting consulting firms, and individuals from the oil and gas industry to learn about oil and gas and come up with our requirements.
Where We Are Headed
• Oklahoma Independent Petroleum Association, OWRB, OFMA, Corporation Commission, and the state legislature are working toward standardizing oil and gas floodplain permitting across the state.
We need a statewide consistent effort
• Some communities are requiring too much.
• Some communities are requiring too little.
• These widely varying requirements are difficult for the O/G industry.
Due Consideration
• Our efforts at permitting the industry must not place undue hardship on a business that is often required to be in the floodplain.
• We are familiar with due consideration with the agriculture industry.
• This is STATE LAW: OS 82 Section 1614
Regulate the industry in an expedient manner, enforcing the minimum NFIP standards
Why is it important to regulate the oil and gas
industry in our floodplains?
Canadian County Oil and Gas Wells
Kingfisher, OK, August 19, 2007
Bartlesville OK, July 3, 2007
Yukon, OK, August 22, 2007
Greenfield, OK, August 19, 2007
Blaine County, OK, August 19, 2007
Pipeline Break, Blaine Co., OK
Canadian County, OK, May 9, 2007
Coffeyville, Kansas, July 2, 2007
REUTERS/Cindy Price/The Coffeyville Journal/Handout
Problems• Many oil and gas companies (including
pipelines) do not know they need a floodplain permit, especially in the unincorporated counties.
• Different communities have different floodplain requirements.
• We have a huge number of unprotected production sites in our state’s floodplains.
So How Do You Find Them?• Look for drilling rigs!• Go through Landmen
– Make sure your county clerk’s office of land records has a prominently displayed floodplain map with permit requirement
• Check your state’s O/G regulatory agency website• Get to know your state’s regulatory agency local
inspector• Road Crossing Permits in your county• County District Shops• Assessor’s Office• Check local newspaper listings
OK Corporation Commission Website
• Screen shot of webpage
Identifying O/G Equipment
• It’s hard to permit if you don’t know what it is!• Different counties and states may have
different types of production and equipment.
Safety
• Get permission to go onto site.• Watch out for dangers at the site.• Safety concerns:
– Poisonous Gas– Chemicals– Energized Electrical Equipment– Potentially Explosive Atmosphere– Armed Landowners
Drilling Rig
Photos courtesy Center for Local Government Technology, OSU
Well Head/Christmas Tree
Photos courtesy Center for Local Government Technology, OSU
Pump Jack
Photos courtesy Center for Local Government Technology, OSU
In-Line Heater
Photos courtesy Center for Local Government Technology, OSU
Separator
Photos courtesy Center for Local Government Technology, OSU
Separator
Photos courtesy Center for Local Government Technology, OSU
Heater Treater
Photos courtesy Center for Local Government Technology, OSU
Tank Batteries
Photos courtesy Center for Local Government Technology, OSU
Tank Batteries
Photos courtesy Center for Local Government Technology, OSU
Production Unit
Photos courtesy Center for Local Government Technology, OSU
Production Unit
Photos courtesy Center for Local Government Technology, OSU
Dehydrator
Photos courtesy Center for Local Government Technology, OSU
Meter Run
Photos courtesy Center for Local Government Technology, OSU
Meter Run
Photos courtesy Center for Local Government Technology, OSU
Compressor
Photos courtesy Center for Local Government Technology, OSU
Compressor
Photos courtesy Center for Local Government Technology, OSU
Workover Rig
Photos courtesy Center for Local Government Technology, OSU
What do the O/G companies have to do to be compliant?
• Get floodplain permit before development begins
• Floodproof, elevate or relocate
• Present you with floodproof or elevation certificate(s) when completed
Specifics
• Establish BFE
• 3 Options:– Elevate site above BFE, Elevation Certificate
required.– Relocate site out of floodplain.– Floodproof: Anchor all production equipment
to BFE; protect vulnerable equipment such as well head with guard to prevent flood debris damage. Floodproof certificates must be provided.
Specifics Continued
• All vulnerable utilities must be above BFE.• A closed mud pit system must be used.• The lease road must be constructed so it will not
obstruct the flow of water.• A culvert must be placed in the barrow ditch
where lease road meets county road.• Tree and brush debris must be removed from
floodplain or burned.
Specifics Continued
• The O/G company should provide you with a list of production equipment on the site.
• O/G company must notify you if– they add new equipment.– they sell the site to another company.
• Make agreement to be able to inspect the site periodically after permit is completed.
Permit Steps
1. Identify site on floodplain map.a) What is the potential water velocity at the site?b) How far would they have to go to get tanks and
equipment out of floodplain?c) Note whether lease road will be under water during
flood or will impede water flow.
2. Visit the site—Know your site!a) Take photosb) Note condition and location of trees and shrubs
Drought
Same site, during a wet year
Permit Steps cont.
3. Collect documents from the O/G companya. Completed permit application form
b. Detailed plans and specs for the site
c. Engineered anchoring plans
d. Staking plat
e. Other applicable permits
f. Spill Prevention and Counter Measure Plan
g. Emergency Evacuation Plan
Permit Steps cont.
4. Floodplain board meets to consider approval of permit.
• Issue permit and checklist.• If necessary schedule an intermediate
inspection.• When development is complete, do final
inspection, collect flood proofing and/or elevation certificates, and take photos.
THIS CERTIFIES THAT
BLAINE COUNTY FLOODPLAIN
PERMIT NO. 26 ___________
HAS BEEN ISSUED TO Continental Resources, Inc.
LOCATION NW/4 Sec 14-T16N-R12W Well Boston Trust 1-14 DATE ISSUED April 2, 2007 BY PHONE 580-623-7283 Local Administrator
POST ON PREMISES IN PLAIN VIEW OF A PUBLIC ROAD
Pipelines
• Have your Floodplain Board establish burial depth requirement.
• Canadian County:– 72 inches under creeks/rivers, 48 inches in the
rest of the floodplain– Must sign Statement of Burial Depth
Compliance
The Good,The Bad and
The Ugly
The Good
Proper anchoring
Proper anchoring
Proper anchoring on equipment other than tanks
Anchoring
Anchoring
Anchoring
Well Head Guard
Elevation of production site
Relocated production equipment
Relocated production equipment
The Bad and the Ugly
Infringement on waterway
Well head guard
Tree debris blocking waterway next to pad
River movement placed well head in river channel
New unpermitted equipment added after final inspection
Our Challenge: Educate and Partner
• Media publicity– Press releases to local newspapers– Commissioners/Council meetings
• Website• Floodplain presentations in community
– Civics groups are always looking for presenters!– Hand out free floodplain maps of the county. People love to get
maps.
• OCC district quarterly meetings• Industry association partnerships
– Oklahoma Independent Petroleum Association– Landmen Associations
TheYukon Review, our partners in
educating the public
Educate the Industry
• Approach them with an attitude of cooperation.• If they don’t know about fp permitting, give them
the benefit of the doubt--the first time only!• There are many different people involved with an
oil and gas site. Educate them all.• A good working relationship with the industry is
the goal.
Canadian County Floodplain Management
201 N Choctaw Ave El Reno, OK 73036
(405) 262-1070 ext 6260 Dear Permit Holder: Enclosed you will find your floodplain permit issued by Canadian County. Please display in a prominent location at the development site. An intermediate and final inspection may be necessary to complete your floodplain development permit process. First:
Please schedule an inspection with me before the foundation is poured on an elevated structure so that any errors in lowest floor elevation can be corrected before the foundation is set.
Please schedule an inspection with me and the flood-proofing engineer or architect before flood-proofing structures are set in place.
No intermediate inspection is required. When your development is completed, please contact me so that I can do the final inspection. Please have the following ready at the final inspection:
Flood proofing certificate(s) signed by a licensed engineer or architect for the following structure(s):_______________________________________ ___________________________________________________________ ___________________________________________________________
Elevation Certificate of the lowest floor (including basement) completed by a licensed engineer, architect, or land surveyor for the following structures:__________________________________________________ ___________________________________________________________ ___________________________________________________________
No certificate needed.
Failure to provide the required certification is a violation of this permit. Your permit is not complete until the final inspection is done and until I have certified that you have fulfilled all the requirements of your permit. If you have any questions, please do not hesitate to contact me. Amy Brandley Date Floodplain Administrator